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CORRESP
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  PO
Box 281077

  Nashville,
TN 37228

 615-476-1151

 SteveMillslaw@gmail.com

August
21, 2025

Securities
and Exchange Commission

Division
of Corporate Finance

Office
of Trade and Services

Washington,
DC 20549

Superstar
Platforms Inc.

Registration
Statement on Form 10-12G

Filed
May I, 2025

File
No. 000-56744

Dear
Sir or Madam:

We
are submitting this letter on behalf of Superstar Platforms Inc. ( “the Company”) in response to comments from the staff
(“Staff”) of the Securities and Exchange Commission (the “Commission”) received by letter on July 24, 2025 relating
to the Company’s Registration Statement filed on Form 10-12g filed on May 1, 2025 with the file number 000-156744 and amended on
July 8, 2025. The numbered paragraphs below correspond to the numbered comments in the Staff’s letter. We are including as an attachment
to this letter a copy of the Registration Statement that has been marked to show changes from the Registration Statement as originally
filed.

Amendment
No. 2 to Registration Statement on Form 10-12G filed July 8, 2025

Item
1A. Risk Factors

We
note your revised disclosure in response to prior comment 3 and reissue. Please further revise the risk factors section to disclose the
risks that are specific to you, your business operations, and your securities.

Current
version:

Item
1A-Risk Factors

RISK
FACTORS

An
investment in our common stock is highly speculative and involves a high degree of risk. In determining whether to purchase Superstar
Platforms Inc.’s common stock, an investor should carefully consider all the material risks described below, together with the
other information contained in this report. An investor should only purchase Superstar Platforms Inc.’s securities if he or she
can afford to suffer the loss of his or her entire investment.

General
Business and Industry Risks

An
inability to retain our senior management team would be detrimental to the success of our business.

We
rely heavily on our senior management team; our ability to retain them is particularly important to our future success. Given the highly
specialized nature of our services the senior management team must have a thorough understanding of our product and service offerings
as well as the skills and experience necessary to manage an organization consisting of a diverse group of professionals and external
parties. In addition, we rely on our senior management team to generate and market our business successfully in a crowded, complex, and
legislatively bound marketplace. Further, our senior management’s personal reputation and relationships with our clients are a
critical element in obtaining and maintaining client engagements. We will enter into non-solicitation agreements with our senior management
team, and we will also enter into well-scoped non-competition agreements. If one or more members of our senior management team leave
and we cannot replace them with a suitable candidate quickly, we could experience difficulty in securing and successfully completing
engagements and managing our business properly, which could harm our business prospects and results of operations.

Our
inability to hire and retain talented people in an industry where there is great competition for talent could have a serious negative
effect on our prospects and results of operations.

 Superstar
Platforms, is a company that seeks to own and control a diversified portfolio of subsidiaries across various industries. Growth will
primarily be driven through strategic acquisitions. Currently Superstar Platforms owns PawnTrust— a specialized marketplace designed
exclusively for the approximately 11,000 pawn shops across the country. The online marketplace (www.pawntrust.com) digitizes the inventory
using advanced image recognition algorithms to automate item descriptions of the participating pawn shops and markets them on a national
scale. The marketplace contains cutting-edge technology that streamlines the borrowing, buying, and bartering transactions typically
found at a pawn shop. These enhancements let consumers experience a frictionless shopping experience on their mobile app that gives them
instant access to this nationwide inventory of pawn shops. Not only does this provide a more efficient way for consumers to shop, eliminating
the need to visit multiple stores, but it also amplifies the reach of individual pawn shop owners. By joining the PawnTrust- ‘Pawn
Partners’ network, shop owners gain access to a broader audience, enhancing their visibility and sales opportunities. This innovative
approach aligns customer convenience with business growth, reshaping how people interact with the pawn industry. Consumers that purchase
items outside of their local area will have their items conveniently shipped to them. As the intermediary in each transaction, PawnTrust
earns a fee on every item sold in the marketplace. Many of these local pawn shops lack an online presence or the capital to market their
inventory on a national scale. By bridging this gap, PawnTrust opens opportunities for incremental sales from a wider buying base, effectively
transforming the pawn shop and micro-lending industries. This model not only supports local businesses but also extends their reach,
driving growth and innovation within the market. .Our success depends largely on our general ability to attract, develop, motivate, and
retain highly skilled professionals. Further, we must successfully maintain the right mix of professionals with relevant experience and
skill sets as we grow, as we expand into new service offerings, and as the market evolves. The loss of a considerable number of our professionals,
the inability to attract, hire, develop, train, and retain additional skilled personnel, or the failure to maintain the right mix of
professionals could have a serious negative effect on us, including our ability to manage, staff, and successfully complete our existing
engagements and obtain new engagements. Qualified professionals are in great demand, and we face significant competition from both senior
and junior professionals with the requisite credentials and experience. Our principal competition for talent comes from other pawnshops
and consulting firms as well as from organizations seeking to staff their internal professional positions. Many of these competitors
may be able to offer significantly greater compensation and benefits or more attractive lifestyle choices, career paths, or geographic
locations than we do. Therefore, we may not be successful in attracting and retaining the skilled people we require to conduct and expand
our operations successfully. Increasing competition for these revenue-generating professionals may also significantly increase our labor
costs, which could negatively affect our margins and results of operations.

Additional
hiring, departures, business acquisitions and dispositions could disrupt our operations, increase our costs, or otherwise harm our business.

Our
business strategy is dependent in part upon our ability to grow by hiring individuals or groups of individuals and by acquiring complementary
businesses. However, we may be unable to identify, hire, acquire, or successfully integrate new employees and acquired businesses without
substantial expense, delay, or other operational or financial obstacles. From time to time, we will evaluate the total mix of products
and services we provide, and we may conclude that businesses may not achieve the results we previously expected. Competition for future
hiring and acquisition opportunities in our markets could increase the compensation we offer to potential employees or the prices we
pay for businesses we wish to acquire. In addition, we may be unable to achieve the financial, operational, and other benefits we anticipate
from any hiring or acquisition, as well as any disposition, including those we have completed so far. New acquisitions could also negatively
impact existing practices and cause current employees to depart. Hiring additional employees or acquiring businesses could also involve
several additional risks, including:

    ●
    the
    diversion of management time, attention, and resources from managing and marketing our Company;

    ●
    the
    failure to retain key acquired personnel or existing personnel who may view the acquisition unfavorably;

    ●
    the
    potential loss of clients of acquired businesses;

    ●
    the
    need to compensate new employees while they wait for their restrictive covenants with other institutions to expire;

    ●
    the
    potential need to raise significant amounts of capital to finance a transaction or the potential issuance of equity securities that
    could be dilutive to our existing shareholders;

    ●
    increased
    costs to improve, coordinate, or integrate managerial, operational, financial, and administrative systems;

    ●
    the
    potential assumption of liabilities of an acquired business;

    ●
    the
    inability to attain the expected synergies with an acquired business;

    ●
    the
                                                                              usage of earn-outs based on the future performance of our business acquisitions may deter the acquired company from fully
                                                                              integrating into our existing business;

    ●
    the
                                                                              perception of inequalities if diverse groups of employees are eligible for different benefits and incentives or are subject to
                                                                              different policies and programs; and

    ●
    difficulties
    in integrating diverse backgrounds and experiences of consultants, including if we experience a The transition period for newly hired
    consultants results in a temporary drop in our utilization rates or margins.

Our
intangible assets primarily consist of customer relationships, trade names, customer contracts, technology, and software. We evaluate
our intangible assets for impairment whenever events or changes in circumstances indicate that the carrying amount of the assets may
not be recoverable. Determining the fair value of a reporting unit requires us to make significant judgments, estimates, and assumptions.
While we believe that the estimates and assumptions underlying our valuation methodology are reasonable, these estimates and assumptions
could have a significant impact on whether a non-cash goodwill impairment charge is recognized and the magnitude of any such charge.
The results of an impairment analysis are as of a point in time. There is no assurance that the actual future earnings or cash flows
of our reporting units will be consistent with our projections. We will monitor any changes to our assumptions and will evaluate goodwill
as deemed warranted during future periods. Any significant decline in our operations could result in additional non-cash goodwill impairment
charges.

Changes
in capital markets, legal or regulatory requirements, and general economic or other factors beyond our control could reduce demand for
our services, in which case our revenues and profitability could decline.

Several
factors outside of our control affect demand for our services. These include:

    ●
    fluctuations
    in the U.S. and world economies;

    ●
    the
    U.S. or global financial markets and the availability, costs, and terms of credit;

    ●
    changes
    in laws and regulations; and

    ●
    other
    economic factors and general business conditions.

We
are not able to predict the positive or negative effects that future events or changes to the U.S. or global economy, financial markets,
or regulatory and business environment could have on our operations.

Changes
in U.S. tax laws could have a material adverse effect on our business, cash flow, results of operations and financial conditions.

We
are subject to income and other taxes in the U.S. at the state and federal level. Changes in applicable U.S. state or federal tax laws
and regulations, or their interpretation and application, could materially affect our tax expense and profitability. The Company has
not filed its federal tax returns for the last 11 years. The Company does not anticipate material adjustments of its tax liabilities
when such returns are filed, but there is no guarantee that such filings will not have a material adverse effect.

If
we are unable to manage fluctuations in our business successfully, we may not be able to achieve profitability.

To
successfully manage growth, we must periodically adjust and strengthen our operating, financial, accounting, and other systems,
procedures, and controls, which could increase our costs and may adversely affect our gross profits and our ability to achieve
profitability if we do not generate increased revenues to offset the costs. As a public company, our information and control systems
must enable us to prepare accurate and timely financial information and other required disclosures. If we discover deficiencies in
our existing information and control systems that impede our ability to satisfy our reporting requirements, we must successfully
implement improvements to those systems in an efficient and timely manner. The nature of our services and the general economic
environment make it difficult to predict our future operating results. To achieve profitability, we must:

    ●
    attract,
    integrate, retain, and motivate highly qualified professionals;

    ●
    achieve
    and maintain adequate utilization and suitable billing rates for our revenue-generating professionals;

    ●
    expand
    our existing relationships with our clients and identify new clients in need of our services;

    ●
    successfully
    resell product/ engagements and secure new client sales/engagements every year;

    ●
    maintain
    and enhance our brand recognition; and

    ●
    adapt
                                                         quickly to meet changes in our markets, our business mix, the economic environment, the credit markets, and competitive
                                                         developments.

Our
financial results could suffer if we are unable to achieve or maintain adequate utilization and suitable billing rates for our products
and services.

It
is likely that our quarterly results of operations may fluctuate in the future because of certain factors, some of which may be outside
of our control.

Superstar
Platforms, Inc owns PawnTrust which is an exclusive online marketplace dedicated to serving the unique needs of pawn shops. Our platform
connects pawn shops with a network of buyers and sellers, creating an efficient marketplace designed to optimize business opportunities
in the pawn industry. In addition to our marketplace services, PawnTrust provides tailored small business lending solutions, with a core
focus on supporting the growth and operational needs of pawn shops. Our lending options offer accessible financing designed to help pawn
shops expand inventory, manage cash flow, and invest in growth initiatives. A
key element of our strategy is to market our products and services directly to certain specific organizations, and to increase the number
of our products and services utilized by existing clients. The sales cycle for some of our products and services is often lengthy and
may involve significant commitment of client personnel. Consequently, the commencement date of a client engagement often cannot be accurately
forecasted. Certain of our client contracts contain terms that result in revenue being deferred and cannot be recognized until the occurrence
of certain events. As a result, the period between contract signing and recognition of associated revenue may be lengthy, and we are
not able to pred